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1(212) 318-6393

yarivkatz@paulhastings.com

April 25,
2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

100 F Street, N.E.

Washington, D.C. 20549

Attention: Benjamin Richie

  Lauren Nguyen

Re: Orchestra BioMed Holdings, Inc.

                                            Amendment No. 1 to Registration Statement on Form S-1 on Form S-3

                                            Filed March 27, 2024

                                            File No. 333-274924

Ladies and Gentlemen:

We are in receipt of the letter, dated April 18, 2024, from the
staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect
to the above-referenced Amendment No. 1 to registration statement on Form S-1 on Form S-3 (the “Registration
Statement”). We are responding to the Staff’s comments on behalf of Orchestra BioMed Holdings, Inc. (“Orchestra”
or the “Company”) as set forth below. Simultaneously with the submission of this letter, the Company is publicly filing
via EDGAR an Amendment No. 2 to the Registration Statement on Form S-3 (“Amendment No. 2”) responding
to the Staff’s comments and updating the Registration Statement.

The Company’s responses set forth in this letter are numbered
to correspond to the numbered comments in the Staff’s letter. For ease of reference, we have set forth each of the Staff’s
comments in italics below followed by the Company’s response to each comment. All capitalized terms used herein but not defined
herein have the meanings assigned to such terms in Amendment No. 2, and all page number references are to the page numbers
of Amendment No. 2.

Registration Statement on Form S-3

Cover Page

 1. We note your response to prior comment 1 and
                                            re-issue in part. Where you disclose the "weighted average per share" price of
                                            common stock, please further revise to disclose the price that the selling securityholders
                                            paid for each of the securities being registered for resale.

Company Response:
The Company has revised the cover page in response to the Staff’s comments.

U.S. Securities and Exchange Commission

April 25, 2024

Page 2

 2. We note your response to prior comment number
                                            4 that "the weighted average price of the shares of common stock being registered .
                                            . . was $6.65" and, therefore, the Company has elected not to include this information.
                                            While the average initial sale price of your common stock is more than the current market
                                            value, there remain selling shareholders that will profit on sales as a result of the lower
                                            initial price for which they purchased their shares. Therefore, these selling shareholders
                                            will have an incentive to sell their shares and that public securityholders may not experience
                                            a similar rate of return on the securities they purchased. Please revise your cover page and
                                            risk factors to include disclosure relating to certain selling shareholders' incentive to
                                            sell.

Company Response:
The Company has provided additional disclosure on the cover page and risk factor disclosure on page 8 in response to the
Staff’s comment.

Risk Factors, page 8

 3. We note your response to prior comment 6 and
                                            re-issue in part. We note the significant number of redemptions of your common stock in connection
                                            with your business combination and that the shares being registered for resale will constitute
                                            a considerable percentage of your public float. Please highlight in a risk factor here the
                                            amount of shares being registered for resale could have a significant negative impact on
                                            the public trading price of the common stock and the attendant risks.

Company Response:
The Company has provided additional disclosure on the cover page and risk factor disclosure on page 8 in response to the
Staff’s comment.

************

If you have any questions concerning Amendment No. 2 or require
any additional information, please do not hesitate to contact me at (212) 318-6393 or yarivkatz@paulhastings.com or Keith Pisani at (212)
318-6053 or keithpisani@paulhastings.com.

Sincerely,

/s/ Yariv Katz

Yariv C. Katz

of PAUL HASTINGS LLP

cc : David Hochman, Chief Executive Officer, Orchestra BioMed Holdings, Inc.

                                            Samuel Waxman, Esq., Paul Hastings LLP

  Keith D. Pisani, Esq., Paul Hastings LLP